Pr. Commissioner of Income Tax-6 Versus Mccain Foods India Pvt. Ltd.

2017 (11) TMI 807 - DELHI HIGH COURT

TPA - MAM - Appropriateness of the Resale Price Method (RPM) - TPO rejected that and applied the Transactional Net Margin Method (TNMM) as the most appropriate and proximate test - Held that:- This Court is of the opinion that the mere circumstance t .....

that if in a given case the aggrieved party is able to show that the rule applied has led to distortion or prejudice as the case may be, the question of law does not arise. In the present case, however, no such factors are present. This question of l .....

A) took a contrary position; that was endorsed by the ITAT being pure finding of fact. The Court is of the opinion that no substantial question of law arises. - ITA 965/2017 - Dated:- 13-11-2017 - MR. S. RAVINDRA BHAT & MR. SANJEEV SACHDEVA JJ. A .....

thod (RPM), which was accepted by the assessee. The TPO, however, rejected that and applied the Transactional Net Margin Method (TNMM) as the most appropriate and proximate test. The CIT(A), however, felt otherwise and reversed the findings of the AO .....